IN RE ZETA GLOBAL HOLDINGS CORP. STOCKHOLDER DERIVATIVE LITIGATION
Filing
15
ORDER granting #14 Motion to Adjourn Conference. Application GRANTED. The initial pretrial conference scheduled for February 4, 2025, and the associated January 30, 2025 deadline to submit a joint case management plan, are ADJOURNED sine die in light of the forthcoming stay request. SO ORDERED. (Signed by Judge Dale E. Ho on 1/28/2025) (jjc)
January 28, 2025
VIA ECF
The Honorable Dale E. Ho
United States District Court
Southern District of New York
Thurgood Marshall United States Courthouse
40 Foley Square
New York, New York 10007
Application GRANTED. The initial pretrial conference
scheduled for February 4, 2025, and the associated January 30,
2025 deadline to submit a joint case management plan, are
ADJOURNED sine die in light of the forthcoming stay request.
SO ORDERED.
Dale E. Ho
United States District Judge
Dated: January 28, 2025
New York, New York
Re: In re Zeta Global Holdings Corp. Stockholder Derivative Litigation, Master File
No.: 1:24-cv-09450-DEH-SDA - Request for Adjournment of Conference
(This Document Relates to All Actions)
Dear Judge Ho:
We represent Defendants David A. Steinberg, Christopher Greiner, John Sculley, Imran
Khan, William Royan, Jené Elzie, William Landman, Robert Niehaus, and Jeanine Silberblatt
(collectively, the “Individual Defendants”), and nominal Defendant Zeta Global Holdings Corp.
(“Zeta,” and collectively with the Individual Defendants, “Defendants”) in the above-captioned
action and write, jointly with Plaintiffs Ashraf Mostafa and Jae Hyung Jung (“Plaintiffs”), pursuant
to Your Honor’s Individual Rule 2.e. regarding scheduling.1
The parties respectfully ask the Court to adjourn the initial pretrial conference scheduled
for February 4, 2025, and the associated January 30, 2025 deadline to submit a joint case
management plan sine die. The parties are currently negotiating a stipulation that would request
the Court to stay the Consolidated Derivative Action in light of the related Securities Class Action.
Accordingly, to conserve the Court’s time and resources, the parties respectfully ask the Court to
adjourn the January 30, 2025 deadline to file a joint letter and proposed civil case management
plan, as well as the initial pre-trial conference scheduled for February 4, 2025, to allow the parties
to finalize their request that the case be stayed, and to submit it for the Court’s consideration and
approval. In addition, pursuant to Your Honor’s Individual Rule 2.e.v., the parties will propose
agreed-upon alternative conference dates in the event that the parties fail to reach an agreement,
or if the Court declines to stay the Consolidated Derivative Action.
This is the first time that the parties have requested an adjournment of the initial pretrial
conference date.
We appreciate the Court’s consideration of this matter.
1
On January 2, 2025, the Court consolidated the Mostafa Action and the Jung Action because they
contain substantially similar factual and legal contentions (the “Consolidated Derivative Action”),
see 1:24-cv-09450-DEH, ECF No. 12; 1:24-cv-09907-DEH, ECF No. 9. Both actions are related
to Davoodi v. Zeta Global Holdings Corp., 1:24-cv-08961-DEH-SDA (the “Securities Class
Action”).
Respectfully submitted,
/s/ Timothy Brown
/s/ Colleen C. Smith
THE BROWN LAW FIRM, P.C.
Timothy Brown2
767 Third Avenue, Suite 2501
New York, NY 10017
Tel: (516) 922-5427
Fax: (516) 344-6204
Email: tbrown@thebrownlawfirm.net
jcoyle@thebrownlawfirm.net
Colleen C. Smith (admitted pro hac vice)
LATHAM & WATKINS LLP
12670 High Bluff Drive
San Diego, CA 92130
Telephone: (858) 523-5400
Email: colleen.smith@lw.com
Attorneys for Plaintiff Mostafa
GAINEY McKENNA & EGLESTON
/s/ Thomas J. McKenna
Thomas J. McKenna
Gregory M. Egleston
Christopher M. Brain
260 Madison Avenue, 22nd Floor
New York, NY 10016
Tel: (212) 983-1300
Fax: (212) 983-0383
Email: tjmckenna@gme-law.com
gegleston@gme-law.com
cbrain@gme-law.com
Megan A. Behrman
Thomas J. Giblin
LATHAM & WATKINS LLP
1271 Avenue of the Americas
New York, NY 10020
Telephone: (212) 906-1200
Email: megan.behrman@lw.com
thomas.giblin@lw.com
Attorneys for Defendants
Attorneys for Plaintiff Jung
cc:
2
All Counsel of Record (via ECF)
Defendants use electronic signatures with consent in accordance with Rule 8.5(b) of the Court’s
ECF Rules and Instructions.
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